PI Assignments from the last /8

The final /8 of address space to be administered by the RIPE NCC is subject to a restrictive delegation policy. In its current form, it can only be used to provide allocations of IPv4 address space to LIRs. This is inherently biased against the large number of organisations which require Provider Independent (PI) assignments of IPv4 address space.

This policy seeks to redress this bias by allowing End Users to receive PI assignments from the last /8.

Summary of Proposal

The final /8 of address space to be administered by the RIPE NCC is subject to a restrictive delegation policy. In its current form, it can only be used to provide allocations of IPv4 address space to LIRs. This is inherently biased against the large number of organisations which require Provider Independent (PI) assignments of IPv4 address space.

This policy proposal seeks to redress this bias by allowing End Users to receive PI assignments from the last /8.

5.6 Use of last /8 for PA Allocations

The following policies come into effect as soon as RIPE NCC is required to make allocations from the final /8 it receives from the IANA. From then on the distribution of IPv4 address space will only be done as follows:

Allocations for LIRs from the last /8 On application for IPv4 resources LIRs will receive IPv4 addresses according to the following:

LIRs may only receive one allocation from this /8. The size of the allocation made under this policy will be exactly one /22.

LIRs receive only one /22, even if their needs justify a larger allocation.

LIRs may apply for and receive this allocation once they meet the criteria to receive IPv4 address space according to the allocation policy in effect in the RIPE NCC service region at the time of application.

Allocations will only be made to LIRs if they have already received an IPv6 allocation from an upstream LIR or the RIPE NCC.

Assignments to Internet Exchange Points

A /16 from the final /8 will be held in reserve for exclusive use by Internet Exchange Points. On application for IPv4 resources, an Internet Exchange Point (IXP) will receive one number resource (/24 to /22) according to the following:

This space will be used to run an Internet Exchange Point peering LAN; other uses are forbidden.

Organisations receiving space under this policy must be Internet Exchange Points and must meet the definition as described in section two of the RIPE document “IPv6 Address Space for Internet Exchange Points”.

IXPs holding other PI IPv4 space for their peering LAN (i.e. they are seeking a larger assignment), must return their old peering LAN resources back to this pool within 180 days of assignment.

New Internet Exchange points will be assigned a /24. Internet exchange points may return this /24 (or existing PI used as an IXP peering LAN) should they run out of space and receive a larger (/23, or /22 if utilisation requires) assignment.

IP space returned by Internet Exchange Points will be added to the reserved pool maintained for Internet Exchange Point use.

Assignments will only be made to IXPs who have already applied for, or received an IPv6 assignment for their peering LAN.

Unforeseen circumstances

A /16 will be held in reserve for some future uses, as yet unforeseen. The Internet is a disruptive technology and we cannot predict what might happen. Therefore it is prudent to keep a /16 in reserve, just in case some future requirement makes a demand of it. In the event that this /16 remains unused at the time the remaining /8 covered by this policy has been distributed, it returns to the pool to be distributed as per clause 1.

Post-depletion Address Recycling

This section only applies to address space that is returned to the RIPE NCC and that will not be returned to the IANA but re-issued by the RIPE NCC itself.

Any address space that is returned to the RIPE NCC will be covered by the same rules as the address space intended in clause 1.

Minimum allocation sizes for the relevant /8 blocks will be updated if necessary

Insufficient address space

In case an allocation of a single /22 as per clause 1 can no longer be made, multiple allocations up to an equivalent of a /22 in address space will be made to fulfill a request.

5.6 Use of last /8

The following policies come into effect as soon as RIPE NCC is required to make allocations from the final /8 it receives from the IANA. From then on the distribution of IPv4 address space will only be done as follows:

Allocations for LIRs from the last /8 On application for IPv4 resources LIRs will receive IPv4 addresses according to the following:

LIRs may only receive one allocation from this /8. The size of the allocation made under this policy will be exactly one /22.

LIRs receive only one /22, even if their needs justify a larger allocation.

LIRs may apply for and receive this allocation once they meet the criteria to receive IPv4 address space according to the allocation policy in effect in the RIPE NCC service region at the time of application.

Allocations will only be made to LIRs if they have already received an IPv6 allocation from an upstream LIR or the RIPE NCC.

Assignments to End Users

On application for IPv4 resources, End Users may receive IPv4 addresses according to the following:

End Users may receive no more than /24 from the final /8, even if their needs justify a larger assignment.

End Users may apply for and receive this assignment once they meet the criteria to receive IPv4 address space according to the assignment policy in effect in the RIPE NCC service region at the time of application.

An assignment will only be made to an End User if they have already received an IPv6 assignment from an upstream LIR or the RIPE NCC.

If an End User is also an LIR, then they may choose to apply for an allocation or an assignment, but they may not receive both.

Assignments to Internet Exchange Points

A /16 from the final /8 will be held in reserve for exclusive use by Internet Exchange Points. On application for IPv4 resources, an Internet Exchange Point (IXP) will receive one number resource (/24 to /22) according to the following:

This space will be used to run an Internet Exchange Point peering LAN; other uses are forbidden.

Organisations receiving space under this policy must be Internet Exchange Points and must meet the definition as described in section two of the RIPE document “IPv6 Address Space for Internet Exchange Points”.

IXPs holding other PI IPv4 space for their peering LAN (i.e. they are seeking a larger assignment), must return their old peering LAN resources back to this pool within 180 days of assignment.

New Internet Exchange points will be assigned a /24. Internet exchange points may return this /24 (or existing PI used as an IXP peering LAN) should they run out of space and receive a larger (/23, or /22 if utilisation requires) assignment.

IP space returned by Internet Exchange Points will be added to the reserved pool maintained for Internet Exchange Point use.

Assignments will only be made to IXPs who have already applied for, or received an IPv6 assignment for their peering LAN.

Unforeseen circumstances

A /16 will be held in reserve for some future uses, as yet unforeseen. The Internet is a disruptive technology and we cannot predict what might happen. Therefore it is prudent to keep a /16 in reserve, just in case some future requirement makes a demand of it. In the event that this /16 remains unused at the time the remaining /8 covered by this policy has been distributed, it returns to the pool to be distributed as per clause 1.

Post-depletion Address Recycling

This section only applies to address space that is returned to the RIPE NCC and that will not be returned to the IANA but re-issued by the RIPE NCC itself.

Any address space that is returned to the RIPE NCC will be covered by the same rules as the address space intended in clause 1.

Minimum allocation sizes for the relevant /8 blocks will be updated if necessary

Insufficient address space

In case an allocation of a single /22 as per clause 1 can no longer be made, multiple allocations up to an equivalent of a /22 in address space will be made to fulfill a request.

Rationale

a. Arguments supporting the proposal

Provider independent assignments provide a critical networking resource to a large number of End Users in the RIPE NCC service region. It is difficult to justify excluding them from the last /8 on what is essentially an arbitrary basis.

A policy of excluding End Users from being able to receive provider independent assignments from the last /8 may attract unwelcome regulatory and/or legal attention for the RIPE NCC.

b. Arguments opposing the proposal

It is likely that PI assignments from the last /8 will cause the last /8 to be consumed faster than if PI assignments were prohibited.

Impact Analysis:

Note: In order to provide additional information related to the proposal, details of an impact analysis carried out by the RIPE NCC are documented below. The projections presented in this analysis are based on existing data and should be viewed only as an indication of the possible impact that the policy might have if the proposal is accepted and implemented.

A. RIPE NCC's Understanding of the Proposed Policy

The RIPE NCC understands that the intent of Policy Proposal 2010-02, “Allocations from the last /8” was to allow new entrants to receive some IPv4 address space next to their IPv6 allocation. The acceptance of Policy Proposal 2012-04 would accelerate the consumption of IPv4 addresses from the last /8, reducing the period in which new entrants would be able to receive IPv4 address space.

The RIPE NCC would like to highlight some details of the implementation:

Regarding the statement in the proposed policy "End Users may receive no more than a /24 from the final /8", the RIPE NCC interprets this to mean that an End User can receive multiple PI assignments from the last /8 as long as the total is no more than a /24.

Regarding the statement in the proposed policy "An assignment will only be made to an End User if they have already received an IPv6 assignment from an upstream LIR or the RIPE NCC", the RIPE NCC interprets this to mean that holding IPv6 address space from an RIR other than the RIPE NCC would not make the End User eligible for an IPv4 PI assignment from the last /8.

B. Impact of Policy on Registry and Addressing System

Acceptance of this proposal would speed up the consumption of addresses from the remaining IPv4 address pool. The exact impact depends on a number of factors.

These factors include:

the rate at which LIRs request their final allocation of IPv4 address space;

the rate at which new LIRs sign up after the RIPE NCC’s pool of IPv4 address space reaches the last /8; and

the rate at which End Users request space from the last /8 if the Proposal is approved.

If the policy proposal is not accepted:

All existing LIRs (8,202 per 1 August 2012) request their /22 allocation within two years of the RIPE NCC reaching the last /8;

New LIRs join the RIPE NCC at the same rate as seen in the last 12 months (average 75 new LIRs per month, from 1 August 2011 to 1 August 2012);

Each new LIR immediately requests and receives their /22 from the last /8;

No PI assignments are allowed

In this case, it could be estimated that the last /8 would be fully used in approximately nine years.

If the policy proposal is accepted, the same assumptions as above could be made and:

End Users request their /24 from the last /8 at the same rate as PI assignments were made by the RIPE NCC in the last 12 months (average 242 IPv4 assignments per month)

In this case, it could be estimated that the last /8 would be fully used in approximately five years.

The RIPE NCC would like to highlight that both these scenarios assume that the LIR growth rate will remain the same for the entire period.

Another scenario assumes that End Users will request PI assignments directly from the RIPE NCC because the upstream LIR they would request a PA assignment from cannot or will not make an assignment to them. In this scenario, it is very difficult to predict what effect this would have on address consumption from the last /8.

Requests smaller and larger than a /24

Finally, under the policy proposal, only requests for a /24 would be approved. This would have implications for those who require less than a /24 of address space or more than a /24 of address space.

End Users who need a small assignment may not qualify for a full /24 and so could not use this policy to obtain a routable prefix.

Those needing larger assignments would have to look for a different solution because a single /24 would not satisfy their needs.

To determine the effect the proposal would have on the consumption of the last /8, it would be reasonable to look at the number of PA assignments from a /25 to a /23. In 2011, about 35,000 PA assignments between a /25 and a /23 were registered in the RIPE Database, excluding INFRA-AW assignments.

Even though it is impossible to predict how many End Users would request PI space if they could not obtain a PA assignment, the number of assignments from a /25 to a /23 could be considered to be an indication of the number of these assignments that would be made.

In the event that the same number of End Users requested PI space as in 2011, the last /8 would be exhausted in less than two years.

Fragmentation/Aggregation:

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact will be caused if this proposal is implemented.

C. Impact of Policy on RIPE NCC Operations/Services

Registration Services:

This proposal limits to a /24 the amount of address space that one End User may receive. Identifying all the assignments that an End User holds can be difficult and time-consuming, involving a substantial amount of administrative work from the RIPE NCC. Much of this work would derive from the large number of languages used in the RIPE NCC and difficulty this means for verifying the correctness of organisation details.

It is also relatively straightforward in many jurisdictions to set up a separate legal entity that could then apply for a PI assignment, resulting in one actual organisation holding multiple /24s from the last /8.

Evaluating requests for PI space carries a higher workload than evaluating other requests due to the extra due diligence checks required to approve the contract and registration documents. Due to the limit of one /24 per organisation and the accompanying requirement to verify company documents, the workload on the RIPE NCC is expected to increase significantly and result in the need for additional staff.

Billing/Finance Department:

This policy proposal could stimulate demand for PI address space over PA address space by introducing a financial incentive to request PI address space. For PA address space, an LIR would only be able to get one /22 from the last /8 of IPv4 address space. For PI address space, on the other hand, they would be able to obtain several /24s for different networks and for different customers (End Users).

A large-scale demand for PI space through sponsoring LIRs rather than concluding a direct contract with the RIPE NCC could lead to a decrease in the growth of new members and may lead to an erosion of the RIPE NCC membership base. The increased workload for the RIPE NCC in assigning PI address space combined with a reduced membership base may lead to increased fees for RIPE NCC members.

RIPE Database:

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant impact on the RIPE Database will be caused if this proposal is implemented.

D. Legal Impact of Policy

After analysing the data that is currently available, the RIPE NCC does not anticipate that any significant legal impact will be caused if this proposal is implemented.

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